Matheson

Practice Areas

Tax

Related Expertise
Tax Brochure
Tax Brochure

Knowledge Development Box
Knowledge Development Box

Irish CbC Reporting for Multinational Groups, Irish Investment Funds and Irish SPVs
Irish CbC Reporting for Multinational Groups, Irish Investment Funds and Irish SPVs

Expertise

International Firm in the Americas
International Tax Review 2017
 
Our tax department is significantly the largest tax practice group amongst Irish law firms. In contrast to the tax departments of other Irish law firms, we operate primarily as a “front-end” service. Significantly more than half of our work is on transactions or advisory matters where our tax professionals have the sole or lead role. We also advise on the taxation aspects of transactions as part of a multi-disciplinary team with lawyers from other groups within the firm. We often act as special tax counsel in transactions where clients require specialised tax advice and are not comfortable using the tax department of their existing legal advisers.  We do not provide tax compliance services.
 
Our dedicated international tax group advises on cross-border transactions in conjunction with legal and tax counsel from other jurisdictions. We have committed considerable resources to building and maintaining good relationships with these lawyers.
 
We advise many leading domestic and international corporations and financial institutions doing business in and from Ireland. We focus on the timely delivery and implementation of integrated leading edge tax advice. Our philosophy is “can do” – if there is a solution we will find it.
 
We are the only Irish law firm to have Irish tax capability on both coasts of the US. In 2011, leading tax adviser John Ryan, was appointed head of the firm’s US offices and is based in New York. Tax partner Mark O’Sullivan is based in our Palo Alto and San Francisco offices.
 
We are consistently ranked as the leading tax law firm in Ireland by the European Legal 500, Chambers Global, American Lawyer, Directors Tax Handbook, World Tax and International Tax Review. We were awarded Irish Tax Firm of the Year 2016 at the International Tax Review European Tax Awards in May 2016, and won European M&A Tax Deal of the Year for the second year in a row at the same ceremony.  In 2015 we were named Irish Transfer Pricing Firm of the Year 2015 by International Tax Review; and also won European M&A Tax Deal of the Year 2015 and European Consumer Products Tax Deal of the Year 2015.
 
We advise on:

General Corporate Tax

We advise leading Irish and international companies across all industries with respect to their inward investment into Ireland, international tax and cross-border planning, corporate reorganisations and restructurings, M&A, demergers, flotations, private equity and joint ventures.

Transfer Pricing

We are the only law firm in Ireland to have been awarded the National Transfer Pricing Firm of the Year accolade by the International Tax Review. Examples of our work in this area include advising on the first transfer pricing adjustment completed under Irish law, the first multilateral transfer pricing adjustment completed under Irish law, and the ground-breaking claim by a non-treaty resident company to correlative relief under an Irish tax treaty. We acted for a number of US multinationals in connection with the judgment of the US Ninth Circuit Court of Appeal in Xilinx v CIR.

Finance Tax

Our finance tax practice covers a broad spectrum of debt based work including banking, structured finance, securitisation, repackaging, debt capital markets, asset finance, project finance and derivatives.
In league tables published each year since 2005 by international financial publisher, Thomson Reuters , Matheson was recognised as having advised more issuers of specialist debt securities in international debt issuance transactions than any other law firm in Europe.

VAT and Indirect Tax

We provide both contentious and advisory VAT advice. We act on a broad range of cases including appeals before the Appeal Commissioners, judicial review applications to the High Court, appeals to the Supreme Court and cases before the European courts. Contentious matters range from the establishment of the VAT treatment for invoice discounting and factoring in Ireland, the application of VAT to real estate transactions, the customs duty classification of internet security devices and the defending of claims for customs duty on withdrawal of GSP preference. On the advisory side, we advise on VAT in a wide range of industries, including financial services, property, retail, travel agency, software and aerospace.

Real Estate Tax

Although primarily focused on general corporate and finance related work, our tax department provides a full range of taxation advisory services to our many clients doing business in and from Ireland. This includes real estate taxation, where we act for various consortia of Irish investors in relation to acquisitions and disposals of commercial real estate portfolios, and also development and financing.

Tax Controversy and Tax Litigation

We have extensive experience in conducting tax controversy work including settlement negotiations with the Revenue Commisioners. We have been involved in some recent high profile tax litigation in the High Court. Certain contentious tax work does not proceed to litigation.

Irish Tax Capability in the United States

We are the only Irish law firm to have Irish tax capability on both coasts of the US. In June 2011, John Ryan, who is widely acknowledged as one of Ireland’s leading international tax advisers, re-located to the firm’s New York office. John has more than 20 years’ experience advising international companies doing business in and from Ireland. He leads a team of tax, corporate and financial services lawyers based in the firm’s US offices, which focuses on advising US companies and financial institutions doing business in and from Ireland. Tax partner Mark O’Sullivan is based in the firm’s Palo Alto office.

Experience Highlights

As tax is a sensitive and confidential topic for many clients, in many cases we are unable to give specific details of particular projects we have undertaken. However, our tax lawyers experience in recent transactions includes advising companies in the following sectors:
  • finance and insurance
  • pharmaceutical
  • fast moving consumer goods
  • technology
  • contract catering
  • energy
  • utilities
  • transport
  • healthcare
  • chemical
  • real estate
  • manufacturing

We have also advised on the tax aspects of a significant number of private corporate transactions (including certain buy-outs of high-value minority positions and transactions to transfer high-value family-owned businesses to the next generation).

Some of our recent public transactions in the area of tax controversy and tax litigation include:
  • advising a major bank in relation to regulatory inquiries ongoing since 1998 in relation to its banking activities
  • advising various US multinationals on the implications of the Xilinx case before the US Ninth Circuit (judgment subsequently reversed by the US Ninth Circuit)
  • representing National Irish Bank in its successful challenge to the Revenue Commissioners on obtaining information held by its Isle of Man branch (currently on appeal to the Supreme Court)
  • advising leading investment banks in respect of stamp duty investigations initiated by the Revenue Commissioners
  • representing RSA Security Systems in its application to the European Court of First Instance, seeking the annulment of EU Commission Regulation 888/2006
  • representing Hagemeyer Ireland plc in its successful judicial review proceedings before the High Court overturning the previous Revenue practice in relation to the VAT treatment of invoice discounting and factoring operations

Accolades

International Firm in the Americas
International Tax Review 2017

European Financial Services Tax Deal of the Year
International Tax Review 2017

Matheson’s substantial team combines "great technical work with a commercial overlay".
European Legal 500 2017

Ireland Tax Firm of the Year
International Tax Review 2016

European M&A Tax Deal of the Year
International Tax Review 2016

"We consistently receive excellent technical and practical tax advice from this firm, deriving from an in-depth knowledge of tax issues and how they apply to our products. The team is very approachable, always quick to respond, and provides superior results."
Chambers Europe 2016

The ‘excellent’ Matheson acts for numerous international clients requiring cross-border structuring advice.
European Legal 500 2016

"The firm gives very thorough analysis and understands our business. The partners are really involved, but there is also a strong wider team which provides a seamless service. The lawyers will roll up their sleeves and find a solution."
Chambers Europe 2016

The ‘excellent’ Matheson has an extensive tax practice, advising on investigations and structuring in the context of M&A and investment funds.
European Legal 500 2016

"The lawyers are responsive and personable, and give great, straightforward advice."
Chambers Europe 2015

"Very thorough and on the ball."
Chambers Europe 2015

"The benchmark for tax advice in Ireland."
European Legal 500 2015

Matheson’s group "provides cross-departmental support that covers all angles".
European Legal 500 2015

Matheson "will always get it done and come through with a creative solution to what seems at first to be an insurmountable problem".
Tax Directors Handbook 2015
 
Ireland Transfer Pricing Firm of the Year
International Tax Review 2015
 
"The team gives world-class international tax advice."
Chambers Europe 2014

"A very experienced, practical and sharp team."
Chambers Europe 2014

"The team is prompt, efficient and straightforward – the service is second to none."
Chambers Europe 2014

Matheson has a leading Irish tax practice.
Tax Directors Handbook 2014

Ireland Tax Firm of the Year
International Tax Review 2013

"An impressive firm of very high-calibre attorneys – enjoyable to work with and attentive to client needs."
World Tax 2013

International Firm in the Americas
International Tax Review 2017
 
Our tax department is significantly the largest tax practice group amongst Irish law firms. In contrast to the tax departments of other Irish law firms, we operate primarily as a “front-end” service. Significantly more than half of our work is on transactions or advisory matters where our tax professionals have the sole or lead role. We also advise on the taxation aspects of transactions as part of a multi-disciplinary team with lawyers from other groups within the firm. We often act as special tax counsel in transactions where clients require specialised tax advice and are not comfortable using the tax department of their existing legal advisers.  We do not provide tax compliance services.
 
Our dedicated international tax group advises on cross-border transactions in conjunction with legal and tax counsel from other jurisdictions. We have committed considerable resources to building and maintaining good relationships with these lawyers.
 
We advise many leading domestic and international corporations and financial institutions doing business in and from Ireland. We focus on the timely delivery and implementation of integrated leading edge tax advice. Our philosophy is “can do” – if there is a solution we will find it.
 
We are the only Irish law firm to have Irish tax capability on both coasts of the US. In 2011, leading tax adviser John Ryan, was appointed head of the firm’s US offices and is based in New York. Tax partner Mark O’Sullivan is based in our Palo Alto and San Francisco offices.
 
We are consistently ranked as the leading tax law firm in Ireland by the European Legal 500, Chambers Global, American Lawyer, Directors Tax Handbook, World Tax and International Tax Review. We were awarded Irish Tax Firm of the Year 2016 at the International Tax Review European Tax Awards in May 2016, and won European M&A Tax Deal of the Year for the second year in a row at the same ceremony.  In 2015 we were named Irish Transfer Pricing Firm of the Year 2015 by International Tax Review; and also won European M&A Tax Deal of the Year 2015 and European Consumer Products Tax Deal of the Year 2015.
 
We advise on:

General Corporate Tax

We advise leading Irish and international companies across all industries with respect to their inward investment into Ireland, international tax and cross-border planning, corporate reorganisations and restructurings, M&A, demergers, flotations, private equity and joint ventures.

Transfer Pricing

We are the only law firm in Ireland to have been awarded the National Transfer Pricing Firm of the Year accolade by the International Tax Review. Examples of our work in this area include advising on the first transfer pricing adjustment completed under Irish law, the first multilateral transfer pricing adjustment completed under Irish law, and the ground-breaking claim by a non-treaty resident company to correlative relief under an Irish tax treaty. We acted for a number of US multinationals in connection with the judgment of the US Ninth Circuit Court of Appeal in Xilinx v CIR.

Finance Tax

Our finance tax practice covers a broad spectrum of debt based work including banking, structured finance, securitisation, repackaging, debt capital markets, asset finance, project finance and derivatives.
In league tables published each year since 2005 by international financial publisher, Thomson Reuters , Matheson was recognised as having advised more issuers of specialist debt securities in international debt issuance transactions than any other law firm in Europe.

VAT and Indirect Tax

We provide both contentious and advisory VAT advice. We act on a broad range of cases including appeals before the Appeal Commissioners, judicial review applications to the High Court, appeals to the Supreme Court and cases before the European courts. Contentious matters range from the establishment of the VAT treatment for invoice discounting and factoring in Ireland, the application of VAT to real estate transactions, the customs duty classification of internet security devices and the defending of claims for customs duty on withdrawal of GSP preference. On the advisory side, we advise on VAT in a wide range of industries, including financial services, property, retail, travel agency, software and aerospace.

Real Estate Tax

Although primarily focused on general corporate and finance related work, our tax department provides a full range of taxation advisory services to our many clients doing business in and from Ireland. This includes real estate taxation, where we act for various consortia of Irish investors in relation to acquisitions and disposals of commercial real estate portfolios, and also development and financing.

Tax Controversy and Tax Litigation

We have extensive experience in conducting tax controversy work including settlement negotiations with the Revenue Commisioners. We have been involved in some recent high profile tax litigation in the High Court. Certain contentious tax work does not proceed to litigation.

Irish Tax Capability in the United States

We are the only Irish law firm to have Irish tax capability on both coasts of the US. In June 2011, John Ryan, who is widely acknowledged as one of Ireland’s leading international tax advisers, re-located to the firm’s New York office. John has more than 20 years’ experience advising international companies doing business in and from Ireland. He leads a team of tax, corporate and financial services lawyers based in the firm’s US offices, which focuses on advising US companies and financial institutions doing business in and from Ireland. Tax partner Mark O’Sullivan is based in the firm’s Palo Alto office.

As tax is a sensitive and confidential topic for many clients, in many cases we are unable to give specific details of particular projects we have undertaken. However, our tax lawyers experience in recent transactions includes advising companies in the following sectors:
  • finance and insurance
  • pharmaceutical
  • fast moving consumer goods
  • technology
  • contract catering
  • energy
  • utilities
  • transport
  • healthcare
  • chemical
  • real estate
  • manufacturing

We have also advised on the tax aspects of a significant number of private corporate transactions (including certain buy-outs of high-value minority positions and transactions to transfer high-value family-owned businesses to the next generation).

Some of our recent public transactions in the area of tax controversy and tax litigation include:
  • advising a major bank in relation to regulatory inquiries ongoing since 1998 in relation to its banking activities
  • advising various US multinationals on the implications of the Xilinx case before the US Ninth Circuit (judgment subsequently reversed by the US Ninth Circuit)
  • representing National Irish Bank in its successful challenge to the Revenue Commissioners on obtaining information held by its Isle of Man branch (currently on appeal to the Supreme Court)
  • advising leading investment banks in respect of stamp duty investigations initiated by the Revenue Commissioners
  • representing RSA Security Systems in its application to the European Court of First Instance, seeking the annulment of EU Commission Regulation 888/2006
  • representing Hagemeyer Ireland plc in its successful judicial review proceedings before the High Court overturning the previous Revenue practice in relation to the VAT treatment of invoice discounting and factoring operations

International Firm in the Americas
International Tax Review 2017

European Financial Services Tax Deal of the Year
International Tax Review 2017

Matheson’s substantial team combines "great technical work with a commercial overlay".
European Legal 500 2017

Ireland Tax Firm of the Year
International Tax Review 2016

European M&A Tax Deal of the Year
International Tax Review 2016

"We consistently receive excellent technical and practical tax advice from this firm, deriving from an in-depth knowledge of tax issues and how they apply to our products. The team is very approachable, always quick to respond, and provides superior results."
Chambers Europe 2016

The ‘excellent’ Matheson acts for numerous international clients requiring cross-border structuring advice.
European Legal 500 2016

"The firm gives very thorough analysis and understands our business. The partners are really involved, but there is also a strong wider team which provides a seamless service. The lawyers will roll up their sleeves and find a solution."
Chambers Europe 2016

The ‘excellent’ Matheson has an extensive tax practice, advising on investigations and structuring in the context of M&A and investment funds.
European Legal 500 2016

"The lawyers are responsive and personable, and give great, straightforward advice."
Chambers Europe 2015

"Very thorough and on the ball."
Chambers Europe 2015

"The benchmark for tax advice in Ireland."
European Legal 500 2015

Matheson’s group "provides cross-departmental support that covers all angles".
European Legal 500 2015

Matheson "will always get it done and come through with a creative solution to what seems at first to be an insurmountable problem".
Tax Directors Handbook 2015
 
Ireland Transfer Pricing Firm of the Year
International Tax Review 2015
 
"The team gives world-class international tax advice."
Chambers Europe 2014

"A very experienced, practical and sharp team."
Chambers Europe 2014

"The team is prompt, efficient and straightforward – the service is second to none."
Chambers Europe 2014

Matheson has a leading Irish tax practice.
Tax Directors Handbook 2014

Ireland Tax Firm of the Year
International Tax Review 2013

"An impressive firm of very high-calibre attorneys – enjoyable to work with and attentive to client needs."
World Tax 2013

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